Advertise for Affiliated Investment Company

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Question:

Is a bank permitted to advertise for an affiliated investment company on the bank's website, such as by offering a link to access the investment company services? If yes, what type of disclosure do we need to provide to the customer?

Answer:

I don't know of any rule which would prohibit the links/advertisements. I believe the bank would need a disclosure similar to the "Not, Not, May" to clearly indicate this is NOT the bank's offering and then associate with that the link takes the reader away from the bank's site, and we'll call this an enhanced speed bump. Note that I'm borrowing existing rules and adding additional precautions to protect the bank from any inference that this is a bank product or that it has any FDIC coverage.
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